Formally Submit Quality Payment Program Comments by December 19

cms-twitter-200The Quality Payment Program final rule with comment period incorporates input received to date. To continue building on a user-centric approach, CMS (@CMSGov) is seeking feedback for future rulemaking. We welcome feedback from patients, caregivers, clinicians, healthcare professionals, Congress and others on how to better achieve the goals of the program. CMS is currently seeking feedback on the topics below through 5 p.m. ET on December 19, 2016.

Under the Merit-based Incentive Payment System (MIPS):

Virtual Groups [81 FR 77074-81 FR 77076]:

We intend to implement virtual groups for the 2018 calendar year performance period and we intend to address all of the requirements pertaining to virtual groups in future rulemaking. We request comments on factors we should consider regarding overall implementation, particularly around:

  • establishing minimum standards for members of virtual groups,
  • how virtual groups could use their data for analytics,
  • whether the initial implementation of virtual groups should be in the form of a pilot study,
  • requirements that could facilitate use of virtual groups to enhance health outcomes and goals such as coordination of care, and
  • use of a group identifier for virtual groups.

MIPS Scoring [81 FR 77288, 81 FR 77284, 81 FR 77286, 81 FR 77282]:

Regarding MIPS Scoring, we seek comment on factors we should consider regarding:

  • approaches for non-outcome measures that cannot be scored (measures that are below the case minimum, lack a benchmark or don’t meet data completeness standards).
  • alternative approaches to establishing measure benchmarks and handling topped out measures.
  • stratifying measure benchmarks by practice size in Year 2.

Non-Patient-Facing [81 FR 77063]:

Non-patient facing is a term we use when referring to clinicians that do not have face-to-face encounters with patients. We request comment on alternative terminology that could be used to reference such clinicians and additional comments on the criteria for designating a group as non-patient facing.

Low-Volume Threshold [81 FR 77063]:

For the transition year, the low-volume threshold excludes Medicare Part B clinicians with less than or equal to $30,000 a year in allowed charges or who see 100 or fewer patients. We request comment on approaches for clinicians that are excluded, for low volume or other exclusions, to opt-in and be subject to payment adjustment in a way consistent with MACRA. Excluded clinicians can now report data but not receive a payment adjustment.

Groups [81 FR 77055]:

We seek comment on approaches to using an identifier so groups with eligible clinicians and non-eligible clinicians can participate, since individual eligibility determinations are made before groups identify themselves to CMS and report data.

Quality Performance Category [81 FR 77161]:

Cross-cutting measures are defined as any measures that are broadly applicable across multiple clinical settings and eligible clinicians, both individually and in a group, within a variety of specialties. We seek comment on factors we should consider regarding overall requirements for cross-cutting measures for future years.

Advancing Care Information Performance Category [81 FR 77209, 81 FR 77216, 81 FR 77226, 81 FR 77275]:

We seek comment on improvement activities bonus’ for the Advancing Care Information Category; threshold for group reporting; Advancing Care Information scoring policies and measures; and data submission mechanisms for future years.

Under the Advanced Alternative Payment Models (APMs):

Other Payer Advanced APMs [APM, 81 FR 77426]:

We seek comment on the overall design of Other Payer Advanced APMs by non-Medicare payers, in establishing the nominal amount standard for the QP Performance Period in 2019 and later.

Nominal Standards [APM 81 FR 77427]:

We seek comment on the amount and structure of the revenue-based nominal amount standard for QP Performance Periods in 2019 and later. Specifically, we seek comment on:

  • (1) – setting the revenue-based standard for 2019 and later at up to 15 percent of revenue; or
  • (2) – setting the revenue-based standard at 10 percent so long as risk is at least equal to 1.5 percent of expected expenditures for which an APM Entity is responsible under an APM.

All-Payer Combination Option [APM 81 FR 77463]:

We seek comment on potential creation of a separate pathway to determine whether Medicaid APMs are Other Payer Advanced APMs prior to a QP Performance Period for the All-Payer Combination Option.

Formally Submitting Comments:

To be assured consideration, formal comments must be received at one of the methods provided below, no later than 5 p.m. ET on December 19, 2016. Though we value your input on public webinars, speaking engagements and via the service center, for rulemaking consideration, only comments received via the methods below are accepted.

In commenting, please refer to file code CMS-5517-FC. Because of staff and resource limitations, we cannot accept comments by facsimile (FAX) transmission. You may submit comments in one of four ways (please choose only one of the ways listed):

Electronically. You may submit electronic comments on this regulation to the Federal Register website. Follow the “Submit a comment” instructions.

By regular mail. You may mail written comments to the following address ONLY:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-5517-FC
P.O. Box 8013
Baltimore, MD 21244-8013.

Please allow sufficient time for mailed comments to be received before the close of the comment period.

By express or overnight mail. You may send written comments to the following address ONLY:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-5517-FC
Mail Stop C4-26-05
7500 Security Boulevard, Baltimore, MD 21244-1850.

By hand or courier. You may deliver (by hand or courier) your written comments ONLY to the following addresses prior to the close of the comment period:

For delivery in Washington, DC:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, SW.
Washington, DC 20201

Please be aware that access to the interior of the Hubert H. Humphrey Building is not readily available to individuals without Federal government identification, commenters are encouraged to leave their comments in the CMS drop slots located in the main lobby of the building. A stamp in clock is available for individuals wishing to retain a proof of filing by stamping in and retaining an extra copy of the comments being filed.

For delivery in Baltimore, MD:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244-1850.

If you would like to deliver your comments to the Baltimore address, call telephone number (410) 786-7195 in advance to schedule your arrival with one of our staff members. Comments erroneously mailed to the addresses indicated as appropriate for hand or courier delivery may be delayed and received after the comment period.